HMRC can issue information notices to UK taxpayers outside the UK, but the practical risks often lie less in the validity of the notice and more in how the enquiry develops.
The Court of Appeal’s decision in HMRC v Bolt Services UK Ltd is not just a private hire vehicle case. It is a reminder that the Tour Operators Margin Scheme is a narrow VAT exception, not a general margin scheme for businesses that buy in and resell travel-adjacent or accommodation-related services.
For businesses that have applied TOMS outside a conventional travel agency or tour operator model, the decision should prompt a careful review of the historic position, current VAT treatment, and exposure to future HMRC enquiry.
